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Hi Everyone my name is Clare Winkel. I am a GSFI auditor and food fraud consultant/trainer based in eastern Australia but I have worked in 14 countries including in Ireland and USA. I work for a company called ICS: www.integritycompliance.com.au
Here is an article I have written recently about a foodfraud methodology and web based risk assessment tool that I have developed at ICS: Food Fraud Scorecard (integritycompliance.com.au) Please go ahead and log onto and register on the website to use your free raw material food fraud assessment credit.
clare.winkel@integritycompliance.com.au
It is a requirement by all GFSI (Global Food Safety Imitative) benchmarked food safety standards and many retailer supplier requirements, to carry out a food fraud vulnerability assessment of a food manufacturers entire supply chain with a very strong emphasis on ranking raw materials for potential vulnerability. The expected outcome of the identification of any potential fraud, is the implementation of mitigation strategies/control measures, to reduce the risk of fraud.
In 2016, Clare Winkel at ICS, developed a risk assessment and ranking method that has been used to assess approximately 800 raw materials for vulnerability to food fraud. This method is based on 3 independent variables: likelihood X detectability X profitability, with the outcome of a single numerical score, that can be easily ranked. In 2023 the team at ICS utilized the food fraud risk assessment method, to develop an online tool to bring automation, efficiency, and consistency to the process: Food Fraud Scorecard: https://foodfraudscore.com/
The Food Fraud Scorecard is designed not only to assist the people to carry out the risk assessment and allocate scarce resources to the areas that need attention the most, but also to provide the evidence that auditors are looking for during audits. This “evidence” created by Food Fraud Scorecard, during the risk assessment process includes:
-Ranking of all food fraud scores, to easily identify those raw materials at higher risk of potential food fraud.
-Risk assessment report for each of the raw materials that your company uses.
-List of reference material used to create the risk assessment report.
We can use one of the ICS clients’ journeys, as a case study of how effective this tool can be, even for a small company with limited raw materials. ICS has undertaken the food fraud risk assessment of their 30 raw materials in 2018, 2021, 2022 & 2023.
The original 30 raw material rankings ranged from the highest score of 60 to the lowest score of 3, out of a possible highest score of 125. (5 x 5 x 5). The next lowest score was 32 then 24. By 2023 the 23 raw materials were ranked from the highest score of 24 to the lowest score of 2.
Yes the raw materials changed over time, as did the suppliers and importantly the scores changed to reflect those changed circumstances: availability, pricing, country of origin….. But the most significant change in the scores, related to one ingredient, cinnamon, that in 2018 started with a score of 60 & in 2022 had a score of 18. The ranking process has enabled the company to identify their major food fraud vulnerability and review the supply chain of cinnamon then make changes.
They changed not just their suppliers, but the entire supply chain so that they knew, not just the country of origin, but could identify each major step in the international chain, along with the controls already in place. For example, in 2018 the cinnamon, was supplied by a broker who gave two different countries of origin, no source manufacturer, no certifications, no certificate of assurance or batch specific lab results. Not only did the supplier not undertake any control measures, the company purchasing the product also did not take any samples, carry out any testing or even basic sensory assessment.
In 2022 that same ingredient was supplied by different wholesaler that has supplied the following information and documentation:
-country of origin.
-name of the source manufacturer.
-current GFSI certificate of the source manufacturer.
-current GFSI certificate of the wholesaler.
-batch specific lab results from the source manufacturer.
The company purchasing the product also undertakes sensory (looks like, smells like, tastes like) evaluation of all received products.
Using the Food Fraud Scorecard, for an ingredient like cinnamon, the likelihood score can be dropped with the addition of further “traceability” information and the profitability score will usually remain stable but it is the detectability score that can be dropped from 5 to 2 with the implementation of methods that will increase the changes of actually picking up the fraud, when it crosses your loading dock. Every company, no matter how small, can implement inexpensive changes that will make a significant difference to the vulnerability of food fraud in their raw materials.
To use the Food Fraud Score you still need to have a detailed knowledge of your raw materials, their supply chain and the actual likelihood of fraud in that supply chain. Additionally, you will need knowledge of the actual controls & checks that your company has in place to identify food fraud when it turns up on your loading dock. I will discuss where you can find this type of information. The more detailed and accurate information you have the more accurate your final raw material ranking scores will be.
The third component is the profitably of undertaking fraud on that raw material. This is directly linked to product shortages and the related price rises. There are specific international websites that can assist with this information but of course your purchasing team should be on top of this information.
If we think about the processor with the cinnamon that started as being ranked as 60. They reviewed their product specification. In Australia this is usually a PIF (Product Information Form) and when this document was reviewed in detail, it identified that the raw material that was assumed to be sourced from a specific species at high risk from fraud, but was actually sourced from a similar, but different species, that was at a lower risk of fraud. This information will lower the likelihood score.
The PIF contains much useful information when you are starting your food fraud assessments- if its completed correctly and completely- including stated information on product description (often listing species botanical name), country of origin, source manufacturer, ingredient declarations, allergens, product description, legal description, allergen management and controls in place, suitability for claims, physical, organoleptic, chemical and microbiological specifications, that can then be matched to information from your direct supplier.
A really crucial, but simple, thing to do is go downstairs and read the information printed on the actual ingredient cartons and bags onsite i.e. manufacturers address. Recently in an audit I had reviewed the food fraud assessments and noted one product was stated to have a country of origin of India. But downstairs I read the packaging, and the product was actually imported from Nigeria. The supplier had not notified the company and the specification stated it was from India. This will make a difference in the final ranking of the raw material for fraud.
The general history of fraud for each ingredient can be identified using a database like HorizonScan https://horizon-scan.fera.co.uk/ This database lists all daily recalls from almost every country in the world along with many national border rejections, covering food safety and food fraud issues for thousands of raw materials and packaging. This enables you to easily and correctly, quantify the risk for that raw material, then that specific country of origin and search for specific suppliers. Horizon Scan can also identify what type of adulterants you should be looking to test for.
Many supplied audit certificates can be matched to that specific standard’s public access database (i.e. BRCGS, SQF & FSSC 22 000), to confirm that it is indeed legitimate. Any discrepancy between stated information in the PIF (specification), audit certificates and certificate of assurance needs to be investigated. If you suspect that the certificate of assurance/lab report you are receiving may be fraudulent, line up 12 months of records to see if the results are identical. Almost no product sourced from plants or animals will be identical all year round. Next step is to take a product sample and get it tested independently at a registered laboratory. Test don’t trust.
Even something easily undertaken like taking a sample of product for each delivery, smelling it, feeling, assessing the colour against a known master sample, can identify batch to batch discrepancies. If a sample is identified as ‘different” to a known sample, then a ‘presence/absence’ test for starch or gluten can often identify additional components, that indicate fraud.
There are also wide range of sophisticated lab tests that can be undertaken to identify food fraud but start with the consistent and complete supply chain information and product sampling to minimise your risk to food fraud in your raw materials.
Know and understand your supply chains, use sensory evaluation, review the detail on the PIF, read the information printed on the actual ingredient cartons, research the history of fraud for each ingredient, identify what type of adulterants you should be looking, obtain valid certificate of assurances and then get it tested independently. Then use all of the supply chain information to carry out your food fraud raw material risk assessments in the Food Fraud Scorecard: https://foodfraudscore.com/